The following memo was delivered to the NC Division of Solid Waste Management's working group on dry-cleaning solvent clean-up.  The memo is BREDL's initiative to have the state add organochlorine elimination to its effort to clean up contaminated commercial dry cleaning sites. There are over 600 operating retail outlets in NC and perhaps 800 abandoned sites.  Experts assume that 90% of drycleaning sites are contaminated with Trichloroethylene, also called perchloroethylene or "perc."  This is a part of our campaign to eliminate the use of chlorine-a dioxin producing element when combined with organic compounds.

BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
PO Box 88  ~ Glendale Springs, North Carolina  28629
Phone 336-982-2691 ~ Fax 336-982-2954 ~ Email bredl@skybest.com

MEMO

To: Dry-Cleaning Solvent Cleanup Act of 1997 Working Group
From: Lou Zeller
Re: Perchloroethylene phase out recommendations
Date: April 9, 1999

North Carolina is poised to lead the nation in the elimination of perchloroethylene.  Our working group has the opportunity to protect and support owner-operators, move forward on clean-ups of contaminated sites and prevention of future ones, and secure the support of industry, environmentalists, and taxpayers.

A growing body of evidence indicates organochlorine compounds including tetrachloroethylene are a serious threat to public health.  Because perc and its breakdown products are toxic, persistent and bioaccumulative in the environment, phase out of this compound is the only rational strategy to reduce and eliminate further injury to dry-cleaning workers, to public health, and to the environment.  Furthermore, safe and effective methods of cleaning are now available to the commercial dry-cleaning industry.  These methods include several wet-cleaning procedures and a recently developed carbon dioxide technique which was invented in North Carolina. Together these methods eliminate the need for both perchloroethylene and other solvent-based dry-cleaning systems.  Moreover, these alternatives eliminate major environmental and public health problems, maintain quality of service to the customer, are economically viable and competitive with current systems, and in some cases reduce cleaning costs.

Therefore, I propose that the Dry-Cleaning Solvent Cleanup Act of 1997 Working Group adopt the goal of eliminating organochlorine dry-cleaning solvents by a date certain.  We must propose regulatory and market mechanisms which will sunset the use of perchloroethylene as soon as possible and which minimize social and economic dislocation. The failure of the DCSCA of 1997 to remedy the problems associated with dry-cleaning business liability and insurance presents us with an opportunity to move towards the elimination of perc.  The increased reliance on a taxpayer-funded strategy for cleanup of contaminated sites and reduction of liability gives the public a greater ability to determine how and when this sunset will occur.

Some  trends already favor the reduction in perc usage: for example, the rising costs of hazardous waste disposal for perc wastes and filters.  Liability and access to capital continue to be problems for an industry using toxic compounds in a consumer product.  The ongoing shift from transfer machines to dry-to-dry machines is an example of a regulatory-driven, market-based substitution which also points towards phase-out of perc.  There are obstacles which must be overcome if an equitable solution is to be found.  For example, the large investment in perc-based equipment, a lack of information about alternative cleaning methods,  and the need for training of present and future industry employees must be addressed of we are to make a smooth transition to a chlorine-free cleaning industry.  But some dry cleaners upon learning of safer alternatives will want to convert immediately.  Others will make the change if offered financial incentives or tax breaks.  The question is: what mechanism can we devise which will move the industry to eliminate perchloroethylene?

The strategy for elimination of perchloroethylene includes the following:
1) Demonstrate the alternatives to the industry and to the public with projects showing the economic viability and health advantages,
2) Provide access to training and technical assistance to dry-cleaning operators,
3) Offer financial incentives to owner-operators for perc phase-out,
4) Link subsidies for contaminated site clean-up to the transition to perc phase-out,
5) Stimulate public demand by educating the public about environmental and public health hazards of perc,
6) Discourage investment in new perc-based dry-cleaning units and associated end-of-tailpipe pollution control, and
7) Set a sunset date with interim targets for the complete elimination of perc.

A typical perc dry-cleaning unit now costs about $50,000-60,000. Commercial wet-cleaning units are available at about $30,000-$35,000.  Carbon dioxide franchises cost about $150,000. The Chapel Hill based Micell Technologies opened its first store in Wilmington in February. The trade journal American Drycleaner in its March issue reported on this new venture saying, “Emblazoned with the cleaner’s logo and brand name, the pristine new plant may signal the next big thing in drycleaning, not only in terms of its environmentally sensitive, user-friendly technology, but also in its market strategy.”   Ted Williams, Sr. of Williams Cleaners, the owner of the new franchise, said,  “It’s the greatest thing in half a century.”

Representative David Price has introduced legislation, HR 1303--The Dry Cleaning Environmental Tax Credit Act of 1999--which allows a 20% credit for dry cleaning equipment which does not use any hazardous solvent, i.e. chlorinated solvent.  We should develop companion legislation for the General Assembly which sunsets the use of perchloroethylene.